                 SUPPORTING STATEMENT FOR RadNet ICR# 0877.15


Section I: Part A

1.  Identification of the Information Collection

      1.(a)	Title of the Information Collection

            RadNet

      1.(b)	Short Characterization

RadNet in this ICR refers to EPA's national environmental radiation monitoring network. The objectives of RadNet are to provide a means of estimating ambient levels of radioactive pollutants in our environment, to follow trends in environmental radioactivity levels, and to detect and assess the impact of fallout and other intrusions of radioactive materials. Data generated from EPA's RadNet have been and are being used to provide the information base for making decisions necessary to ensure the protection of public health. The system enables EPA to determine if additional sampling or other actions are required in particular cases of radioactive releases to the environment, and, where necessary, RadNet can provide ancillary information on population exposure, radiation trends, and other aspects of such releases.

The RadNet network is used to collect air particulate, precipitation, and drinking water samples. RadNet air particulate monitors are capable of measuring radiation from the filter in real-time, sending the data hourly to EPA. The data from analysis of these samples constitute the nation's single major source of environmental radiation data. The responsibility for operating RadNet is assigned by the EPA's Office of Radiation and Indoor Air to the Director, National Analytical Radiation Environmental Laboratory (NAREL), in Montgomery, Alabama. The component sampling locations are distributed throughout the United States and cover each geographical region, individual states, and most major population centers. The respondents, primarily state and some local officials, voluntarily collect the samples and complete the information forms. The forms request descriptive information related to sample collections (e.g., sample type, sample location, length of sampling, and volume represented). Requested sampling frequencies are as follows:

 Air particulate samples are requested twice weekly. *

 Precipitation samples are collected after each measurable rainfall and composited into monthly samples.

 Drinking water samples are collected quarterly.

      *   Many variables and site-specific conditions may preclude predicting a specific number of filters changed by a respondent weekly. For example, operator safety may be compromised by construction or severe weather, which may preclude routine air sample collection. Reduced operator availability may cause reduced filter change frequency if an operator's non-volunteer job duties increase, or if frequency of their visits to a RadNet site decreases, such as may occur with sites at remote locations generally visited in conjunction with non-volunteer job duties. The RadNet Quality Assurance Project Plan contains a detailed discussion of these conditions. It is important to recognize that these variations do not affect the quality of the results of the analyses.

Beginning in July 2016, EPA began adding exposure rate measurement to the real-time RadNet air monitors. Exposure rate data provide more useful information to the public and general scientists concerning gamma radiation in the environment. To date, ninety-nine RadNet air monitors have this capability. Exposure rate measurement capability is only added to a monitor when its gamma radiation monitoring components require servicing. Addition of exposure rate measurement capability will continue as the gamma radiation components require servicing, which is expected to take several more years.

The samples are sent to NAREL for radiochemical analyses. To ensure that the data generated at NAREL are of known quality, a quality assurance plan (available upon request) is followed during all phases of sample collection and analysis activities. 

Data are stored electronically at NAREL and are available online at www.epa.gov/radnet. See Attachment 1 for the forms used by respondents and NAREL personnel to document sampling in all RadNet media:  air, precipitation, and drinking water.

The utility of RadNet data is evidenced by its extensive use by a number of federal, state and commercial entities. DOE's National Laboratories (including Oak Ridge, Savannah River, Brookhaven, and Argonne) and many universities across the country utilize the data generated by the operation of the RadNet network. RadNet data are also used by the Nuclear Regulatory Commission (NRC) and NRC licensed nuclear power plants and their environmental contractors to establish background data. These data are used by some power plant operators as a baseline to ensure compliance with NRC release limits. The states also use RadNet data to supplement or compare with environmental radiation information generated by their own programs. RadNet data are also available to the public via the EPA website. More than one million "hits" were recorded on the EPA website following the Fukushima nuclear reactor accidents.

Data from this program have been used to measure fallout following atmospheric nuclear weapon tests until 1980, when atmospheric testing of nuclear weapons ceased. During and following the accident at Three Mile Island in 1979, RadNet stations in the adjacent states demonstrated to the public that there were no radioactive materials in their areas as a result of the accident. Increased monitoring following the nuclear incident at Chernobyl in 1986 provided daily reports of atmospheric concentrations of radionuclides across the United States. Most recently, RadNet was the largest source of radiological data in the U.S. following the Fukushima reactor accidents in 2011. RadNet also responds to smaller events such as the ruthenium-106 detections in Europe in 2017 and the reported detections of man-made radionuclides in the atmosphere in northern Europe in mid-June 2020.

The collection of samples will involve 213 respondents with an annual respondent burden cost of approximately 159,395 dollars, including costs of benefits and overhead. The respondents are not asked or required to keep records and all supplies and equipment relating to RadNet activities are provided by NAREL at no cost to the respondents.
   
RadNet data back to 1981 may be found at the EPA web site www.epa.gov/radnet. RadNet data on the web are interactive--the database can be queried and searched. Quarterly reports are no longer produced due to the availability of RadNet data online. NAREL does not survey respondents, other than on specific issues regarding their activities as sample collectors. That is done through routine conversations with them via telephone or e-mail as part of the process of maintaining the flow of samples and supplies between NAREL and respondents.

Expansion of the real-time air network of RadNet to 140 monitors is complete. The size of the other media networks (drinking water and precipitation) are typically expected to remain essentially unchanged, except for the normal fluctuation of volunteer participants. However, the COVID-19 pandemic resulted in a loss of 30% of the drinking water sampling locations. This loss of drinking water sampling locations is the primary reason for a reduction in burden of 2.2% since the last ICR.

2.  Need for and Use of the Collection

      2.(a)	Need / Authority for the Collection
      
The legal basis of RadNet originated and resides in Executive Order 10831 and Public Law 86-373. Executive order 10831 was announced to the public on July 31, 1959, and issued August 4, 1959. This order came in response to recommendations contained in a memorandum to the President from Elmer B. Staats on July 31, 1959. As reiterated before the Joint Committee on Atomic Energy by Maurice H. Stans, these recommendations also became a part of the legislative history of the 1959 amendments to the Atomic Energy Act. Radioactive fallout and environmental radiation monitoring became a responsibility of the Department of Health, Education and Welfare (HEW) under these legal mandates. In 1970, Reorganization Plan No. 3 transferred HEW's fallout and radioactive monitoring responsibilities to the Environmental Protection Agency (EPA). On July 1, 1973, through its Office of Radiation Programs (ORP), EPA developed and implemented a new continuous monitoring system. This system, originally called the Environmental Radiation Ambient Monitoring System and now called RadNet, was designed to complete and complement the monitoring system previously instituted by HEW's Public Health Service under Executive Order 10831.

The objectives of RadNet are to provide a means of estimating ambient levels of radioactive pollutants in our environment, to follow trends in environmental radioactivity levels, and to assess the impact of fallout and other intrusions of radioactive materials. Data generated from EPA's RadNet have been and are being used to provide the information base for making decisions necessary to ensure the protection of public health. The system enables EPA to determine if additional sampling or other actions are required in particular cases of radioactive releases to the environment, and, where necessary, RadNet can provide ancillary information on population exposure, radiation trends, and other aspects of such releases.

      2.(b)	Use / Users of the Data

Data generated by RadNet are used to provide a means of estimating ambient levels of radioactive pollutants in our environment, to follow trends in environmental radioactivity levels, and to detect and assess the impact of fallout and other intrusions of radioactive materials. Data generated from EPA's RadNet have been and are being used to provide the information base for making decisions necessary to ensure the protection of public health. The system enables EPA to determine if additional sampling or other actions are required in particular cases of radioactive releases to the environment and, where necessary, RadNet can provide ancillary information on population exposure, radiation trends, and other aspects of such releases.

The utility of the RadNet data is evidenced by its extensive use by a number of federal, state and commercial entities. DOE's national Laboratories (including Oak Ridge, Savannah River, Brookhaven, and Argonne) and many universities across the country utilize the data generated by the operation of the RadNet network. RadNet data are also used by the Nuclear Regulatory Commission and NRC licensed nuclear power plants and their environmental contractors to establish background data. These data are used by some power plant operators as a baseline to ensure compliance with NRC release limits. The states also use RadNet data to supplement or compare with environmental radiation information generated by their own programs.

Data from this program have been used to measure fallout following atmospheric nuclear weapon tests until 1980, when atmospheric testing of nuclear weapons ceased. During and following the accident at Three Mile Island, RadNet stations in the adjacent states demonstrated to the public that there were no radioactive materials in their areas as a result of the accident. Increased monitoring following the nuclear incident at Chernobyl in 1986 provided daily reports of atmospheric concentrations of radionuclides across the United States. RadNet was the largest source of radiological data following the Fukushima reactor accidents in 2011. Most recently, the RadNet air monitoring program responded to detections of ruthenium-106 in Europe in 2017 and the reported detections of man-made radionuclides in the atmosphere in northern Europe in mid-June 2020. RadNet continuously monitors the nation's air for abnormalities.

3.	Non-duplication, Consultations, and Other Collection Criteria

      3.(a)	Non-duplication	

RadNet has been in operation for over 50 years. During that time, data derived from the system have been disseminated nationally and internationally. The professional/information network developed over the life of RadNet has identified other environmental radiation data systems in the United States, but none have RadNet's national scope or exact collection and analytical structure. This was highlighted during the months following the nuclear reactor accidents in Fukushima, Japan as well as in response to detections of man-made radionuclides in Europe in 2017 and 2020.

Immediately following the accident at Chernobyl in 1986 in the former Soviet Union, the President's order charged EPA with lead responsibility for monitoring possible environmental effects in the United States. It was the unique nationwide monitoring capability of RadNet that helped EPA respond to that Presidential Order. Similarly, during the nine-year EPA follow-up monitoring of the accident at Three Mile Island, RadNet was called upon because of its unique national scope and analytical structure and capability.


      3.(b)	Public Notice Required Prior to ICR Submission to OMB

The first Federal Register (FR) notice will be completed and published by 6/30/2023.
      

      3.(c)	Consultations

The National Analytical Radiation Environmental Laboratory (NAREL) is involved in telephone and written communication with the respondents who supply the samples. In addition, NAREL is an active participant in the Council of Radiation Control Program Directors (CRCPD), which is an association of individuals from radiation programs from all fifty states. These individuals and their associates make up a significant number of RadNet data users. NAREL's participation in this association allows for frequent consultations on a variety of issues involving RadNet with many RadNet data users. Comments from federal and state agencies and other organizations concerning RadNet are welcomed and are noted at NAREL. 

      3.(d)	Effects of Less Frequent Collection

Alternate, less frequent collection intervals have been considered but not adopted because these would not provide the continuous current "picture" of the radiation levels across the United States now available with the current system. Less frequent collection would impact RadNet several ways including drastically reducing the ability to determine and respond to elevated radiation levels soon after they occur, decreasing the ability to map trends in radiation data, and reducing data availability significantly.

      3.(e)	General Guidelines
      
The respondents are requested to supply precipitation samples and air filters and accompanying forms more often than on a quarterly basis. This is done so that elevated levels of radiation will be detected as soon as possible so as to allow for the quickest response possible to potential health threats. 

The respondents submit sample collection information on a one page form that accompanies the sample to the NAREL. Since most samples are collected in the field, electronic means of recording or sending the information are not feasible. In addition, to avoid assigning incorrect sampling information to a sample, the sample and sampling information need to be linked when they are sent to the lab. The most effective means to do this is to attach a form with the information to the sample.

      3.(f-g)	Confidentiality and Sensitive Questions	

The section on confidentiality and sensitive questions does not apply to RadNet. The respondents do not supply confidential or sensitive information.

4.  The Respondents and the Information Requested

      4.(a)	Respondents / NAICS Codes

All fifty states, primarily Public Health Departments (NAICS Code 92312), send samples along with one page sample collection forms to NAREL. The respondents were chosen for two basic reasons: most of them routinely collect samples of this type as part of their normal activities, and in order to obtain meaningful information concerning ambient radiation levels for the entire United States, samples must be collected from as many parts of the country as feasible.
 
      4.(b)(i)	Information Requested

Respondents provide actual samples of air, precipitation, and drinking water. Respondents provide descriptive information about their samples on one page forms (see Attachment). The respondents are not requested or required to maintain records. Since the forms, as shown in the attachment, have had only very minor changes over time, expiration dates are not included on them. 

      4.(b)(ii)	Respondent Activities	

RadNet respondents perform the following tasks in order to provide samples to NAREL:

 Read instructions concerning the sampling process
 Collect samples in appropriate containers
 Mail/ship samples to NAREL in Montgomery, Alabama
 Complete description forms regarding samples

Most respondents are employees of state or local health agencies and routinely perform sampling of their own that is analogous to RadNet sampling. 

5.	The Information Collected

      5.(a)	Agency Activities

Since RadNet began operating in the early 1970's, the following functions have been part of EPA's inventory of Agency activities:

 Maintain a master database
 Answer respondent questions
 Coordinate respondent sample submissions
 Maintain records of sample submissions
 Publish and disseminate data from sample analyses
 Analyze samples submitted by respondents
 Prepare and send sampling supplies
 Provide maintenance and or replacements for sampling instruments

      5.(b)	Collection Methodology and Management

The RadNet network involves the collection of a variety of samples including air filters, drinking water, and precipitation samples. Standard Operating Procedures (available upon request) contain the detailed procedures used to ensure uniform collection of the samples and the standard forms filled out by the respondents when they collect the samples. The forms were designed to minimize the burden on the respondents. In most cases only the date of sampling, location of sampling, and the name of the individual taking the sample are required. Since most samples are taken in the field, an electronic means of recording and sending this information is not feasible. To ensure that the sample collection information accompanies the correct sample, the sample and the information need to be sent together. This is best accomplished by including the one page form with each sample when it is sent to the NAREL.

When the samples and accompanying forms arrive at NAREL, the samples are assigned an identification number. This number and information from the accompanying forms are entered into the NAREL database. The samples are then analyzed for a variety of radionuclides. Data from the analyses performed at NAREL are also entered into the database. The data are available to the public online at the EPA website www.epa.gov/radnet. When necessitated by unique circumstances, data from the RadNet network can be made available daily. The data are verified by at least two individuals at NAREL. To ensure that the data are accurate and reliable, all activities associated with the RadNet network must conform to the Quality Assurance Manuals, which detail the data quality objectives, project organization and responsibility, internal quality control checks, and other areas relating to quality assurance. 

      5.(c)	Small Entity Flexibility

This section is not applicable because most respondents are state agencies.

      5.(d)	Collection Schedule

Listed below are the requested sample collection frequencies that require completion of sample collection forms.

      Sample					Requested Collection frequency

      Drinking water				Quarterly
      Precipitation				As measureable precipitation occurs
	Air filters				Two times per week *

      *   Many variables including site-specific conditions may preclude predicting a specific number of filters changed by a respondent weekly. For example, operator safety may be compromised by construction or severe weather, which may preclude routine air sample collection. Reduced operator availability may cause reduced filter change frequency if an operator's non-volunteer job duties increase, or if frequency of their visits to a RadNet site decreases, such as may occur with sites at remote locations generally visited in conjunction with non-volunteer job duties. The RadNet Quality Assurance Project Plan contains a detailed discussion of these conditions. It is important to recognize that these variations do not affect the quality of the results of the analyses.

In the rare case of an emergency, such as Three Mile Island, Chernobyl, or Fukushima, EPA may request an increased sample collection frequency.	


6.	Estimating the Burden and Cost of Collection

      6.(a)	Estimating Respondent Burden

Total individual respondent burden for RadNet is estimated to be 3,640 hours annually. This 2.2 percent reduction in burden from 3,722 hours annually indicates that the RadNet network is fully established and operating with essentially no changes expected with the exception of the loss of 30% of the drinking water sampling locations during the COVID-19 pandemic. EPA continues to look for ways to reduce operator burden. 

Burden hour estimates are based primarily on sample collection times tested by NAREL personnel and informal telephone conversations with respondents over the years. Additional information used in estimating burden hours was obtained through discussions of NAREL personnel with personnel from state radiation departments at Council of Radiation Control Program Directors (CRCPD) meetings. Discussions with respondents and RadNet management revealed that the technical labor category is the most appropriate one for all RadNet burden activities.

Although the respondent burden assumes 213 total sampling locations, there can be times when the actual number of stations reporting is less than that, mainly due to unexpected nonparticipation by some station operators. However, participation is not anticipated to decrease by more than 5 percent in any single year.
	
      6.(b)	Estimating Respondent Cost

Total respondent cost for RadNet is estimated to be about $159,395 annually. This represents an 8.6 percent increase in cost from $146,759 annually, even though there are fewer respondents, is caused by increasing the hourly salary estimate for the respondents as discussed in the next paragraph.

Informal conversations and discussions with respondents and RadNet management have revealed that the technical labor category is the correct one for all RadNet respondent burden activities. Since the hourly wages of the respondents depend on years of employment and the pay scales of their respective states, an actual average hourly wage would require obtaining confidential information from the respondents. Based on our informal discussions with respondents and RadNet managers, the hourly rate at the GS-9(1) level, 43.79 dollars/hour ($27.37 per hour times a 1.6 overhead multiplication factor, based upon OPM salary tables for "rest of U.S." effective April 2023 as displayed at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2023/RUS_h.pdf), is a good approximation of the respondents' hourly wage for this technical labor category. 

The respondents are not asked or required to keep records, and all supplies and materials relating to RadNet activities are provided by the NAREL at no cost to the respondents.

There are no capital costs for sample collectors (respondents). All equipment and materials are supplied by NAREL. 

      6.(c)	Estimating Agency Burden and Cost

Our agency burden estimates are based on our years of experience in operating the RadNet network. Since the activities for the operation of RadNet involve workers at various GS levels, we used composite burden hours and calculated hourly costs at the GS-13 level (step 1) times 1.6 (the overhead multiplication factor) to be 75.52 dollars/hour. 

The estimated agency burden remains 27,672 hours as in the previous ICR because operations are essentially constant. Total agency cost for RadNet activities and capital costs, including supplies, are estimated to be about $2,622,124 annually. The 10.9% estimated increase in agency personnel cost from $1,831,176 to $2,031,271 annually reflects updated civil service salaries to 2023 levels. The estimate of hours and cost of agency personnel devoted to RadNet are shown in Table 2. Additionally, the EPA estimates the cost for supplies for the RadNet program to be $77,700  annually. This 11.0% increase in supplies cost from $70,000 to $77,700 reflects increased costs of supplies. Finally, the Agency estimates the capital costs to increase from $462,300 to about $513,153 due to increased costs. Hence, the total burden for capital costs on the agency is $590,853, as shown in Table 3.

	6.(d)	Bottom Line Burden Hours and Cost/Burden Tables

See burden tables on pages 11-13.

      6.(e)	Reasons For Change in Burden

Total respondent burden remains essentially unchanged, with exception of fewer respondents due to the COVID-19 pandemic. Otherwise, the system has been operating steadily with minimal changes for the past six years. EPA will continue to look for ways to reduce burden while maintaining an effective monitoring program.
      
      6.(f)	Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average approximately 0.24 hours per response. Burden means the total time and effort expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15. 

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID No. EPA-HQ-OAR-2003-0041-0011, which is available for online viewing at www.regulations.gov, or in person viewing at the Office of Air and Radiation Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA/DC Public Reading Room is open from 8 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is 202-566-1744, and the telephone number for the Office of Air and Radiation Docket is 202-566-1742. Use EPA's electronic docket and comment system at www.regulations.gov, to submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the docket that are available electronically. Once in the system, select "docket search," then key in the docket ID number identified above. Please note that EPA's policy is that public comments, whether submitted electronically or in paper, will be made available for public viewing at www.regulations.gov as EPA receives them and without change, unless the comment contains copyrighted material, CBI, or other information whose public disclosure is restricted by statute. For further information about the electronic docket, go to www.regulations.gov.

Section II: Part B

In the case of the RadNet network, respondents send in actual samples such as air filters, drinking water, and precipitation. With each sample the respondents send in a one page form which basically requires the date and location of sampling, the size of the sample, and the name of the individual taking the sample. This is basic information that identifies the sample and requires no real data gathering on the part of the respondent. The respondent simply supplies information on the sampling process that he/she just performed.

The design of RadNet makes it the most comprehensive radiation monitoring network in the nation. The 213 sampling sites span the United States and cover most major population centers in all geographical regions. They are typically located at or near state health facilities and samples are collected voluntarily by state or local officials. Although the choice of sampling station locations is not based on a truly randomized design, the nationwide dispersion of sites does represent a close approximation to randomly selected locations with consideration given to population centers as well as geographical coverage of the U.S. This arrangement maximizes the coordination with state and local agencies collecting the samples as it does not place stations in extremely remote and relatively inaccessible locations.

The RadNet network satisfies the three major objectives of an environmental monitoring program as set forth by the Health Physics Society's Committee on Upgrading the Quality of the Environmental Data (EPA 520/1-80-012). These objectives are:

      a.	to assess dose,
      b.	to determine any trends of environmental radiation dose rates and concentrations of radioactive materials, and 
      c.	to reassure members of the public and governmental organizations regarding radiation hazards and environmental radiation exposures.

The Health Physics Society specifically references EPA's RadNet as an example of a functioning environmental monitoring program that incorporates these major desirable features. 
                                       
                                   TABLE 1*

                    Annual Respondent Burden Cost Estimates
                                   Activity
                             Hours per Occurrence
                                      (A)
                             Occurrences per Year
                                      (B)
                         Hours per Respondent per Year
                                  (C = A x B)
                             Respondents per Year
                                      (D)
                            Burden-hours per years
                                  (E = C x D)
                               Cost per year ($)
                             (F = E x $43.79/hr)**
Read Instructions
                                       





    Air 
                                      0.5
                                       1
                                     0.50
                                      140
                                      70
                                     3,065
    Precipitation 
                                      0.5
                                       4
                                     2.00
                                      26
                                      52
                                     2,277
    Drinking water
                                      0.5
                                       4
                                     2.00
                                      47
                                      94
                                     4,116

                                       
                                       
                                       
                                       
                                       
                                       
Collect Samples
                                       
                                       
                                       
                                       
                                       
                                       
    Air
                                     0.167
                                      104
                                     17.37
                                      140
                                     2432
                                    106,497
    Precipitation
                                     0.250
                                      28
                                     7.00
                                      26
                                      182
                                     7,970
    Drinking  Water
                                     0.033
                                       4
                                     0.13
                                      47
                                       6
                                      263

                                       
                                       
                                       
                                       
                                       
                                       
Complete and Mail Forms
                                       
                                       
                                       
                                       
                                       
                                       
    Air
                                     0.050
                                      104
                                     5.20
                                      140
                                      728
                                    31,879
    Precipitation
                                     0.083
                                      28
                                     2.32
                                      26
                                      60
                                     2,627
    Drinking Water
                                     0.083
                                       4
                                     0.33
                                      47
                                      16
                                      701







                              TOTAL ANNUAL  HOURS
                                     3,640








                           TOTAL ANNUAL  LABOR COST

                                    159,395







                      RESPONDENTS' TOTAL ANNUAL COST***

                                    159,395
* Round-off errors may affect the numbers as shown. These errors are insignificant.
** The rate used in this table is that of a GS-9/1 for 2019. The $43.79 per hour amounts to the GS-9/1 "Rest of US" rate of $27.37/hour multiplied by an overhead rate of 1.6.
*** Record keeping costs, capital costs, and maintenance costs are zero (0) for respondents.



					TABLE 2

                      Annual Agency Burden/Cost Estimates
                                 (Activities)
Line Item
                                Burden Activity
                                 Annual Hours
                               Agency Costs ($)*
1
Maintaining master database
                                      50
                                     3,776
2
Monitoring real-time data (contractor)
                                     3,288
                                  230,160 **
3
Monitoring real-time data (NAREL)
                                      500
                                    37,760
4
Maintain real-time monitors (contractor)
                                     6,480
                                  473,040 **
5
Maintain system operations (NAREL)
                                     1,500
                                    113,280
6
IT support (contractor)
                                     1,920
                                  120,960 **
7
Answering respondent questions
                                      210
                                    15,859
8
Coordinating respondent submissions
                                     1,462
                                    110,410
9
Maintaining records of samples
                                     1,462
                                    110,410
10
Publishing and disseminating data
                                      300
                                    22,656
11
Analyzing samples
                                    10,000
                                    755,200
12
Providing sampling supplies
                                      500
                                    37,760

TOTAL
                                    27,672
                                   2,031,271

* For federal employees, the activity costs assume an average of GS-13/1 rate time 1.6 ($75.52/hr). Lines 2, 4, and 6 are contractor costs. GS hourly rates are based upon 2023 data from the Office of Personnel Management (https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2023/RUS_h.pdf).
** For contractor activities, costs of those activities are estimated based on previous costs for those activities multiplied by the percentage increase in GS13/1 salary since the previous ICR.

					TABLE 3

                 Agency Burden/Cost Estimates (Capital Costs)
Line Item 
Unit Cost ($)
No. Units
Total ($)
Physical site preparation for air samplers
                                     3,330
                                       3
                                     9,990
Supplies to field stations 
                                      555
                                      140
                                    77,700
Maintain real-time monitors parts (annual total)
                                    166,500
                                       1
                                    166,500
Maintain real-time monitors (contractor site visits, annual total)
                                    199,800
                                       1
                                    199,800
IT costs 
                                       
                                       
                                       
 Data disaster recovery site
                                    24,420
                                       1
                                    24,420
 Oracle license
                                    16,650
                                       1
                                    16,650
 Internet access
                                    19,980
                                       1
                                    19,980
 FTP software
                                      555
                                       1
                                      555
 Records retention
                                     1,998
                                       1
                                     1,998
 Backup software
                                     6,660
                                       1
                                     6,660
 Equipment refresh
                                    11,100
                                       1
                                    11,100
 CDX website host
                                    55,500
                                       1
                                    55,500
                                  Grand Total
                                    590,853


					TABLE 4

                 Summary of Respondent and Agency Total Costs
                                   Line Item
                                   Total ($)
Annual Respondent Burden
                                    159,395
Annual Agency Burden for Activities
                                   2,031,271
Annual Agency Burden for Capital Costs
                                    590,853
Combined (activity and capital cost) Burden
       to the Agency
                                   2,622,124
                                       
                                  ATTACHMENT
                                       
                                       
                                       
                       Forms Used by RadNet Respondents
                           (click on PDF icon below)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
